Institutions with Strategic Plans | Public File Checklist

1. There is no need to review each branch or each complete public file during every examination. In determining the extent to which the institution’s public files should be reviewed, consider the institution’s record of compliance with the public file requirements in previous examinations, its branching structure and changes to it since its last examination, complaints about the institution’s compliance with the public file requirements, and any other relevant information.

2. In any review of the public file undertaken, determine whether branches display an accurate public notice in their lobbies, a complete public file is available in the institution’s main office and at least one branch in each state, and the public file available in the main office and in each state contains:

a. A copy of the approved strategic plan;

b. All written comments from the public relating to the institution’s CRA performance and any responses to them for the current and preceding two calendar years (except those that reflect adversely on the good name or reputation of any persons other than the institution);

c. The institution’s most recent CRA Performance Evaluation;

d. A map of each assessment area showing its boundaries and, on the map or in a separate list, the geographies contained within the assessment area;

e. A list of the institution’s branches, branches opened and closed during the current and each of the prior two calendar years, their street addresses and geographies;

f. A list of services (loan and deposit products and transaction fees generally offered, and hours of operation at the institution’s branches), including a description of any material differences in the availability or cost of services between those locations;

g. The institution’s CRA Disclosure Statement(s) for the prior two calendar years;

h. A quarterly report of the institution’s efforts to improve its record if it received a less than satisfactory rating during its most recent CRA examination;

i. HMDA Disclosure Statements for the prior two calendar years for the institution and for each non-depository affiliate the institution has elected to include in assessment of its CRA record, if applicable;

j. The number and dollar amount of consumer loans, for large banks, if applicable; and

k. The loan-to-deposit ratio, for small institutions.

3. In any branch review undertaken, determine whether the branch provides the most recent public evaluation and a list of services generally available at its branches and a description of any material differences in the availability or cost of services at the branch (or a list of services available at the branch).

 

SOURCE:  Strategic Plan CRA Examination Procedures | OCC, FRB, FDIC, and OTS | July 2007

Related Articles

Leave A Comment?

You must be logged in to post a comment.